People v. Pride
California Court of Appeal
242 Cal. Rptr. 3d 297, 31 Cal. App. 5th 133 (2019)
- Written by Tiffany Hester, JD
Facts
Five men approached D.C. in a San Deigo parking lot and robbed D.C., taking D.C.’s shoes, hat, tablet, watches, and gold-chain necklace. D.C. told police that one of the robbers had a facial scar and yelled, “This is West Coast!” A gang-unit detective believed the robber D.C. described could be gang member Chaz Pride (defendant). Through an undercover police profile, the detective sent a friend request to Pride’s social-media account, and Pride accepted the friend request. Without a warrant, the detective viewed and saved a video that Pride posted after the robbery. The video showed Pride wearing D.C.’s gold-chain necklace and saying, “Check out the new chain, dog.” The State of California prosecuted Pride for robbery. The trial court admitted into evidence the video Pride posted on social media. The jury convicted Pride, and Pride appealed. Pride argued that the detective violated the Fourth Amendment by using an undercover profile to access Pride’s social-media video without a warrant.
Rule of Law
Issue
Holding and Reasoning (McConnell, J.)
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